21 December 2022

Sharon Clipperton and Steven Lloyd –v- HMRC

Laura Poots, led by Aparna Nathan KC, acted for HMRC in successfully arguing that this avoidance scheme failed.  The decision of the Upper Tribunal aligns with its previous decision in Dunsby v HMRC [2021] UKUT 0289, in which Laura represented HMRC.

The decision considers the interpretation and application of the distribution legislation, together with the settlements code.

To view a copy of the decision please click here